Privacy Policy

Data Controller Information

Easy English Tenses ("we", "our", or "the app") is developed and operated by:

This Privacy Policy explains how we collect, use, and protect your information when you use our mobile application, in compliance with GDPR, CCPA, COPPA, and EU Digital Markets Act requirements.

Information We Collect

Local Data (Stored on Your Device Only)

The following data is stored exclusively on your device and never transmitted:

• Learning progress and quiz scores
• App usage statistics and session duration
• User preferences (theme, speech rate, pronunciation language)
• Practice history and achievement data

Important: This data remains on your device, is not accessible to us, and can be deleted by uninstalling the app.

Analytics Data

We collect anonymized usage analytics through two services:

1. Aptabase Analytics

• App launch and feature usage events
• General device information (iOS version, device model)
• Session duration and app performance metrics
• Error and crash data for debugging purposes

Privacy Protection: Aptabase generates anonymous user IDs using SHA(Client IP + User Agent + Daily Rotated Salt), preventing correlation across different days or apps. Data is stored in the European Union (Germany).

2. Google Analytics (Website)

• Website traffic and user behavior analytics
• Page views, session duration, and user interactions
• Geographic location (country/city level)
• Device and browser information
• Referral sources and marketing campaign performance

Privacy Protection: We use Google Analytics 4 with Consent Mode v2, which respects your privacy choices. Analytics cookies are only set with your explicit consent via our cookie banner.

Control: You can accept or reject analytics cookies through our website's cookie consent banner, or manage preferences in your browser settings.

3. Apple App Store Analytics

• App download and installation statistics
• Crash reports (only from users who opted-in via iOS settings)
• Basic usage metrics (only from users who opted-in via iOS settings)

Control: You can opt-out of Apple analytics through your iOS Settings → Privacy & Security → Analytics & Improvements.

Future Data Collection (Planned Features)

We may introduce the following features in future updates:

• In-App Purchases: Transaction data processed by Apple (we don't receive payment information)
• AdMob Advertising: Google AdMob may collect advertising identifiers and serve personalized ads

Notice: We will update this privacy policy and notify users before implementing any new data collection practices.

Legal Basis for Data Processing (GDPR)

For EU residents, we process data based on:

• Legitimate Interest (Article 6(1)(f)): Aptabase analytics to improve app functionality and user experience
• Consent (Article 6(1)(a)): Google Analytics cookies and Apple analytics (via respective opt-in mechanisms)
• Contract Performance (Article 6(1)(b)): Local data storage necessary for app functionality

Cookie Policy

Our website uses cookies to enhance your browsing experience:

Essential Cookies

• Website functionality and security
• Cookie consent preferences
• These cookies are necessary and cannot be disabled

Analytics Cookies (Optional)

• Google Analytics 4 cookies for website performance measurement
• User behavior analytics and marketing effectiveness
• Set only with your explicit consent via cookie banner

Your Control: You can accept, reject, or modify your cookie preferences at any time through our cookie banner or browser settings. Rejecting analytics cookies will not affect website functionality.

Children's Privacy (COPPA Compliance)

Our app is designed to be safe for users of all ages, including children under 13. We do not knowingly collect personal information from children under 13 years of age. The anonymized analytics we collect cannot be used to identify or contact individual users, including children.

Parental Rights: If you believe your child's personal information has been collected, please contact us immediately at [email protected].

Your Rights Under GDPR (EU Residents)

If you are located in the European Union, you have the following rights:

• Right of Access: Not applicable - we don't store identifiable personal data
• Right to Rectification: Not applicable - we don't store identifiable personal data
• Right to Erasure: Delete the app to remove all local data; analytics data is already anonymized
• Right to Restrict Processing: You can disable analytics in iOS settings
• Right to Data Portability: Your local learning data can be manually exported if needed
• Right to Object: Contact us to opt-out of anonymous analytics
• Right to Lodge a Complaint: You may file complaints with your local data protection authority

Your Rights Under CCPA (California Residents)

If you are a California resident, you have the following rights:

• Right to Know: We collect anonymized usage analytics as described above
• Right to Delete: Contact us to request deletion of analytics data (though it's already anonymized)
• Right to Opt-Out of Sale: We do not sell personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

Data Sharing: We do not sell, rent, or share personal information with third parties for monetary consideration.

EU Digital Markets Act (DMA) Compliance

The EU Digital Markets Act designates Apple as a gatekeeper service for the App Store, iOS, and iPadOS. This affects how our app is distributed and processed in the European Union.

Current Distribution

• Apple App Store: Primary distribution channel with standard Apple terms
• Apple Notarization: Our app undergoes Apple's DMA-required notarization process for accuracy, functionality, safety, security, and privacy
• Gatekeeper Data Collection: Apple may collect additional data for app distribution purposes under DMA requirements

Alternative Distribution (EU Rights)

Under DMA, EU users have the right to install apps from alternative sources. While we currently distribute only through the App Store, EU users may in the future access our app through:

• Alternative app marketplaces (if we choose to distribute there)
• Direct website distribution (if we implement web distribution)
• Third-party app stores approved under DMA

Note: Any alternative distribution would maintain the same privacy protections and data handling practices described in this policy.

DMA User Rights in the EU

• Browser Choice: EU users can select alternative browsers as default (affects website cookie consent)
• App Marketplace Choice: Right to install apps from alternative sources
• Interoperability: Enhanced device connectivity and feature access under DMA Article 6(7)
• Transparency: Enhanced information about app distribution and data processing

Data Retention

• Local Data: Stored on your device until you delete the app
• Aptabase Analytics: Retained for up to 5 years for trend analysis
• Google Analytics: Default retention of 26 months, can be reduced upon request
• Apple Analytics: Managed by Apple according to their retention policies

International Data Transfers

Your data may be transferred and processed in:

• European Union: Aptabase analytics data is stored in Germany
• United States: Google Analytics and Apple services may transfer data to the US under appropriate safeguards

All transfers comply with GDPR adequacy decisions or use appropriate safeguards such as Standard Contractual Clauses.

Data Security

We implement appropriate technical and organizational measures to protect your data:

• Local data is protected by iOS security features and device encryption
• Analytics data is transmitted over encrypted connections (HTTPS/TLS)
• We use reputable third-party services with strong security practices
• Regular security reviews of our data handling practices

Third-Party Services

We use the following third-party services:

• Aptabase: EU-based analytics service - Privacy Policy
• Google Analytics: Website analytics with Consent Mode v2 - Privacy Policy
• Apple App Store: App distribution and basic analytics - Privacy Policy

Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or applicable laws. When we make material changes, we will:

• Update the "Last updated" date at the top of this policy
• Provide notice through the app or our website
• For significant changes, obtain your consent where required by law

Contact Us

For any questions about this Privacy Policy, data protection concerns, or to exercise your rights, please contact us:

Supervisory Authorities

If you have concerns about our data handling practices, you may contact:

• EU Residents: Your local Data Protection Authority
• Poland (Lead Authority): Urząd Ochrony Danych Osobowych (UODO)
• California Residents: California Attorney General's Office